They can use a multi for the complex requirements, can't they? (Possibly assuming they get the commercial multi before the single engine...I haven't looked at the requirements for a while.)
Yes, but they will still have minimum requirements in the single for other stuff.
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§ 61.129
Aeronautical experience.
(a)For an airplane single-engine rating. Except as provided in
paragraph (i) of this section, a
person who applies for a commercial pilot certificate with an
airplanecategory and single-engine class
rating must log at least 250 hours of
flight time as a pilot that consists of at least:
(1) 100 hours in powered
aircraft, of which 50 hours must be in airplanes.
(2) 100 hours of pilot-in-command
flight time, which includes at least -
(i) 50 hours in airplanes; and
(ii) 50 hours in cross-country flight of which at least 10 hours must be in airplanes.
(3) 20 hours of training on the areas of operation listed in
§ 61.127(b)(1) of this part that includes at least -
(i) Ten hours of
instrument training using a view-limiting device including attitude
instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Five hours of the 10 hours required on
instrument training must be in a
single engine airplane;
(ii) 10 hours of training in an
airplane that has a retractable landing gear, flaps, and a controllable pitch
propeller, or is turbine-powered, or for an applicant seeking a single-engine seaplane
rating, 10 hours of training in a seaplane that has flaps and a controllable pitch
propeller;
(iii) One 2-hour cross country flight in a
single engine airplane in daytime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure;
(iv) One 2-hour cross country flight in a
single engine airplane in nighttime conditions that consists of a total straight-line distance of more than 100 nautical miles from the original point of departure; and
(v) Three hours in a
single-engine airplane with an
authorized instructor in preparation for the
practical test within the preceding 2 calendar months from the month of the test.
(4) Ten hours of solo
flight time in a
single engine airplane or 10 hours of
flight time performing the duties of
pilot in command in a
single engine airplane with an
authorized instructor on board (either of which may be credited towards the
flight time requirement under
paragraph (a)(2) of this section), on the areas of operation listed under § 61.127(b)(1) that include -
(i) One cross-country flight of not less than 300 nautical miles total distance, with landings at a minimum of three points, one of which is a straight-line distance of at least 250 nautical miles from the original departure point. However, if this requirement is being met in Hawaii, the longest segment need only have a straight-line distance of at least 150 nautical miles; and
(ii) 5 hours in
night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern) at an
airport with an operating control tower.